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Recognition and enforcement of foreign judgments in Uruguay

Argentina. For full detail on Argentina, go to The Argentine Thread.

Last verified: 2026-10-27 · Status: Stable

Foreign money judgments are enforced in Uruguay after an exequatur before the Suprema Corte de Justicia, which checks eight formal and due process conditions but never reviews the merits; its decision cannot be appealed. Since 1 October 2024 Uruguay also applies the 2019 Hague Judgments Convention to judgments from other contracting states (among them the EU states, the United Kingdom and Ukraine), where proceedings began once the Convention was in force between both states. Mercosur judgments can travel by letter rogatory through Central Authorities under the Las Leñas Protocol; foreign insolvency judgments are recognized under the insolvency law.

USD figures use UYU 40.214 per US dollar, the BCU quotation for DLS. USA BILLETE on 26 October 2026, retrieved from the BCU quotations service on 27 October 2026. Amounts set in UR use UYU 1,940.77, the latest published UR value (September 2026, Decreto 229/026, IMPO values table); amounts in UI use UYU 6.6792 per UI (BCU, 27 October 2026). Conversions are rounded and for orientation only.

Key facts

Court for enforcement of foreign judgments	Suprema Corte de Justicia, single instance, no appeal CGP art. 541, as of 2026-10-27 · in force
Review of the merits of foreign judgments	No CGP art. 538.2, as of 2026-10-27 · in force
Term for the debtor to answer an exequatur	20 daysCGP art. 541.2, as of 2026-10-27 · in force
Party to the 2019 HCCH Judgments Convention	Yes, ratified 1 September 2023 Ley 20.117, as of 2026-10-27 · in force
2019 HCCH Judgments Convention in force for Uruguay	2024-10-01 dateLey 20.117, as of 2026-10-27 · in force
Mercosur Las Leñas Protocol on judicial cooperation approved	Yes (Ley 16.971, 1998) Ley 16.971, as of 2026-10-27 · in force

The rule

1. Absent a treaty, foreign judgments in civil, commercial, family, labour and administrative matters, and the civil effects of criminal judgments, have binding, evidentiary and enforceable effect in Uruguay without review of the merits if they: are authentic in the state of origin; are legalized (unless sent through diplomatic, consular or administrative channels); are translated; come from a court with international jurisdiction under its own law, except matters of exclusive Uruguayan jurisdiction; followed proper service on the defendant; ensured due defence; are res judicata in the state of origin; and do not manifestly breach Uruguay's international public policy. The applicant files an authentic copy of the judgment, authentic copies proving service and defence, and a certificate that it is final.
Cost to do it: Apostille or legalization, translation and certified copies of the judgment, of proof of service and of finality; the CGP sets no exequatur fee.
Example: A Paraguayan judgment against a Uruguayan company must be filed with certified proof that the company was served and that the judgment is final. / A New York money judgment for US$750,000 (about UYU 30,160,500) needs an apostilled certified copy, apostilled proof of service and a certificate of finality, plus Spanish translations.Código General del Proceso (Ley Nº 15.982), Book II Title X Chapter IV, art. 524, 537, 538 and 539, 1988-10-18 official text · verified 2026-10-27

2. Only foreign judgments ordering performance can be enforced. Enforcement is requested from the Suprema Corte de Justicia, which serves the other party with 20 days to answer, hears the Fiscal de Corte and decides with no appeal; if it grants enforcement, the judgment goes to the competent lower court, which enforces it under the rules for domestic judgments. Where only the binding or evidentiary effect of a foreign judgment is invoked (for example as a defence of res judicata), it is presented to the court hearing the case, which decides after hearing the public prosecutor. Before ruling, the court asked to enforce may take protective measures at a party's request.
Cost to do it: Counsel before the Supreme Court; enforcement costs before the lower court as for any judgment.
Example: A Chilean judgment ordering a Montevideo SRL to pay CLP is enforced only after the Supreme Court exequatur; then the Montevideo court attaches assets. / A foreign creditor with a US$750,000 judgment can ask for attachment of the debtor's Uruguayan assets while the exequatur is pending (art. 533).Código General del Proceso, art. 533, 540 and 541, 1988-10-18 official text · verified 2026-10-27

3. Uruguay signed the HCCH Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters on the day it was adopted, approved it by Ley 20.117, deposited its ratification on 1 September 2023, and the Convention entered into force for Uruguay on 1 October 2024. Under it, a judgment from another contracting state is recognized and enforced without review of the merits if it meets one of the jurisdictional filters (for example the defendant's habitual residence or branch in the state of origin, express consent, appearance on the merits without objection, or a contract performed in that state) and is refused only on the listed grounds (defective notice, fraud, manifest incompatibility with public policy, inconsistent judgments, among others). Procedure follows Uruguayan law. It excludes, among others, family matters and successions, insolvency, carriage of passengers and goods, validity of companies and of public registry entries, defamation, privacy, most competition matters and arbitration, and applies only if the Convention was in effect between both states when the claim was filed in the state of origin.
Cost to do it: No security for costs may be required of the applicant merely for being foreign or non resident (Convention art. 14).
Example: A judgment from a court in Spain (an EU state bound since 1 September 2023) in a case filed after 1 October 2024 against a Montevideo company falls under the Convention. / A United Kingdom judgment for US$500,000 in a case filed after 1 July 2025, when the Convention entered into force for the UK, can use the Convention's grounds; US judgments cannot, since the United States has only signed.Ley Nº 20.117 (approval of the 2019 HCCH Judgments Convention), Ley 20.117 single article; Convention art. 2, 4, 5, 7, 13 and 16, 2023-03-22 official text · verified 2026-10-27 · changed: The Convention entered into force for Uruguay on 1 October 2024 (HCCH status table).

4. Among Mercosur states, the Las Leñas Protocol of 27 June 1992, approved by Ley 16.971, applies to recognition and enforcement of judgments and arbitral awards in civil, commercial, labour and administrative matters, and to civil damages ordered in criminal cases. Requests by courts go by letter rogatory through the Central Authority. The decision must be authentic, translated, from a court with jurisdiction under the requested state's rules on international jurisdiction, given after proper summons and defence, final, and not manifestly contrary to public policy; recognition depends on there being no incompatible decision or earlier proceedings between the same parties in the requested state. Partial recognition is possible, and the requested state's law governs the procedure. Citizens and permanent residents of the member states, and companies constituted there, cannot be required to post security for costs for being foreign.
Cost to do it: Requests via Central Authorities avoid legalization; translations into Spanish are required for Brazilian decisions.
Example: A Brazilian commercial judgment against a Uruguayan importer can reach Uruguay by letter rogatory through the Central Authorities. / An Argentine judgment for the equivalent of US$100,000 can rely on the Mercosur protocol, signed by Argentina, Brazil, Paraguay and Uruguay; for the Argentine side see The Argentine Thread guide.Ley Nº 16.971 (Las Leñas Protocol), Protocol art. 3, 4, 18, 19, 20, 22, 23 and 24, 1998-06-15 official text · verified 2026-10-27

5. A foreign judgment declaring a debtor's insolvency or bankruptcy is recognized in Uruguay if given by a competent judge, final, issued after the debtor had an opportunity of defence, not contrary to international public policy, and compliant with CGP art. 537 to 543. Uruguayan judges can open insolvency proceedings when the debtor has its domicile or effective centre of activity in Uruguay, or has or had an office, establishment or operation there. Foreign and local creditors are treated alike, except that privileged labour claims have priority over assets in Uruguay, and reciprocity applies if Uruguayan creditors are not admitted on equal terms in the debtor's home state, except for secured claims.
Cost to do it: Same exequatur documents as for any foreign judgment, plus insolvency counsel.
Example: An Argentine bankruptcy order over a company with assets in Montevideo must meet art. 243 before it has effect in Uruguay. / A US Chapter 11 debtor with a Uruguayan branch can be placed in concurso in Uruguay because it has an establishment there (art. 239).Ley Nº 18.387 (Insolvency), art. 239, 242 and 243, 2008-10-23 official text · verified 2026-10-27

Origin	Regime	Key feature	Source
HCCH 2019 contracting state (e.g. EU states, United Kingdom, Ukraine, Montenegro, Albania, Andorra)	Hague Judgments Convention	Jurisdictional filters; closed list of refusal grounds; claim filed after entry into force for both	Ley 20.117; HCCH status table
Mercosur state	Las Leñas Protocol	Letter rogatory via Central Authority; no security for costs	Ley 16.971
Any other state	CGP art. 537 to 543	Supreme Court exequatur, 8 conditions, no appeal	CGP
Foreign insolvency order	Ley 18.387 art. 243	Recognition plus CGP requirements	Ley 18.387

Which regime for a foreign judgment

State	Entry into force
European Union	1 September 2023
Ukraine	1 September 2023
Uruguay	1 October 2024
United Kingdom	1 July 2025
Montenegro	1 March 2026
Albania	1 March 2026
Andorra	1 June 2026
United States	Signed 2 March 2022, not ratified
Argentina	Not a party

HCCH 2019 Judgments Convention, selected entry into force dates

Worked example

A German machinery maker obtains a Munich judgment for EUR against a Montevideo buyer in a case filed in 2025. Because the Convention was in force between the EU and Uruguay when the claim was filed, it applies (Convention art. 16): the buyer had its habitual residence in Uruguay, but the contract was to be performed in Germany, a jurisdictional filter (art. 5.1 g). The seller files a complete certified copy of the judgment and proof that it is enforceable in Germany (art. 12), with translations; no security for costs may be required (art. 14). If the buyer had defaulted, proof of service is also needed. A US creditor with a similar Florida judgment for US$750,000 would instead use the CGP exequatur before the Supreme Court.

Step by step

Identify the regime: Hague 2019 (check both states' entry into force and the filing date), Las Leñas for Mercosur, or the CGP default.
Obtain certified copies of the judgment, proof of service and defence, and a certificate of finality or enforceability; apostille them (Ley 18.836).
Have them translated into Spanish.
File with the Suprema Corte de Justicia under CGP art. 541 (or follow the Convention or Protocol channel), and request protective measures if assets may move (art. 533).
After exequatur, enforce before the competent lower court.

Common traps

Default judgments without solid proof of service are the most common reason for refusal (CGP art. 539.1 numeral 5).
Only judgments ordering performance are enforceable; declaratory judgments only have binding or evidentiary effect (CGP art. 540 and 541.1).
The Hague 2019 Convention does not cover judgments in cases filed before it was in effect between both states (Convention art. 16).
Matters of exclusive Uruguayan jurisdiction, such as real rights over property in Uruguay, block recognition (CGP art. 539.1 numeral 4; Ley 19.920 art. 61).

Sources

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